April 17, 2015

United States Department of Transportation Docket Management System 1200 New Jersey

Ave., SE Washington, DC 20590 Attention: Flight Standards Service Director Dear Mr. Duncan,
We at Photo Elevations LLC sincerel y thank you for your time and consideration for the following review.

**Re: Expedited Exemption Petition of Section 333 of the FAA**  **Reform Act**  **of 2012 to Operate**  **Sm all**  **Unmanned Aircraft**  **Systems (sUAS)**  **For Commercial**  **Purposes Under**  **the New**  **“Blanketed” (COA)**  **Below 200**  **feet Above**  **Groun d**  **Level (AGL)**  **policy for following Pursuant:**
Photo Elevations LLC Michael Finnegan, Owner/Operator 2508 Eagle Lane NE Bemidji, MN 56601 218

- 368

- 1375 photoelevations@yahoo.com I, Michael Finnegan, sole owner/operator of Photo Elevations LLC, prepared the following document. The use of the terms, “I” “My” “We” “Our” or “The Company” from here forth within this document refer to Photo Elevations LLC.

**Photo Elevations**  **LLC respectfully**  **requests exemption**  **fro m**  **the following**  **Federal Aviation Administration (FAA) regulations:**  14 CFR Part 21, Subpart H, 14 CFR Part 27, 14 CFR sections 45.23(b), 61.101(e)(4) and (5), 61.113(a), 61.23(a) and (c), 61.315(a), 91.103, 91.105, 91.109, 91.119, 91.121, 91.151(a), 91.203 (a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), 91.7(a). 

### About Photo Elevations LLC and UAS Commercial Applications Based in Bemidji, MN, Photo Elevations LLC is a small, yet, rapidl y growing company that is dedicated towards addressing a wide variety o f photographic applications both on and off the ground. Our Aerial Division foresees an abundance of opportunity and discovery . Our initial requests for service have come with a strong demand from the Real Estate and Land Development markets. H owever, as the technology quickly p roves its value, we will be heavily focused on agricultural monitoring of growth, development and deficiencies, as well as, commercial advertising, public safety services, such as, searchand rescue emergenc ies, lake

- ice safety monitoring and first responder for hazardous

condition assessments like material spills and fires, both controlled and wild. W e also project a wide variety of Environmental Safety and Conservation applications in the near future. Thi s could include botanical and wildlife studies and safety assessments, as well as, forest canop y monitoring and expedited detection of invasive species like the Pine Bark Beetle, Emerald Ash Borer or the Forest Tent Caterpillar into Minnesota territories. 

### About Michael Finnegan, Owner/Operator, Photo Elevations LLC I, Michael Finnegan, a long time advocate and hobbyist of many varied UAS’s, graduated from Brooks Institute of Photography, Santa Barbara, CA in 1996 with a BA in Illustration and Advertising Photography along with a Minor in Audio/Visual Photography and Videography. My pertinent collegiate resume also includes Meteorology

c ourses at Montana State University. My decades experience and professionalism in difficult situation photography for commercial purposes is very v ast. During my career, I have always placed public, crew and overall operational safety on the highest plateau. A s an Ambassador of an amazingl y new technology, Photo Elevations LLC will always strive to be an exemplary representative of proper UAS’s integration into National Air Space (NAS) for commercial applications. Our safety protocols and paramount professionalism will never be compromised.



### Pilot In Command (PIC) Training Requirements Photo Elevations LLC strongl y believ es the safe integration of UAS’s into National Air Space (NAS) is of the utmost importance and is wanting/willing to adhere to any additional regulations imposed by the FAA in order to maintain the NAS safety and security.
In order to maintain and advance those necessary s afety and security protocols of an emerging industry, Any/All Photo Elevations LLC PIC’s must possess and complete the following FAA and Operator requirements before any consideration for commercial flight takes place:
1. All PIC’s must complete appropriate Pilot School training and pass the Aeronautics Knowledge Test conducted b y the Federal Aviation Administration. 2. All PIC’s must be vetted by the Transportation Safety Administration (TSA). 3. All PIC’s must complete and log a minimum of 10 0 hours of advanced flight simulation time using our Real Flight Professional RF 7.5 flight simulation training programs. 4. All PIC’s must complete and log a minimum of 40 hours actual hands on flight training at our privatel y owned, expansive and rural located training facility

. 5. All PIC’s must possess advanced safety training and knowledge, as well as, advanced training in Pre & Post flight planning, maintenance, checklists, etc.. 6. All PIC’s must pass Photo Elevations LLC strictl y monitored final flight test s.
The Photo Elevations LLC Operator and PIC’s would also strictly respect any

/all further requirements and regulations set by the FAA including but not limited to the following:1. The UAS must weigh less than 55 pounds, including payload.

2. Operations for c losed

- set motion picture and television filming are not permitted. 3. The UAS would never exceed a speed of 87 knots (100 miles per hour). 4. All flights are strictly l imited to the current COA height of less than **200 feet**  above ground level (AGL). Any higher altitudes would require a new COA approval from the FAA. 5. The UAS must be operated within the unaided visual line of sight (VLOS) of the PIC at all times. 6. The Operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition f

or safe flying. 7. Pre and Post Flight safety inspections and documentation. 8. No flight operations will be held at night and conducted under visual meteorological conditions (VMC). 9. The UA will not operate within 5 nautical miles (NM) of any airport with an operational tower; or 3 NM from an airport with a published instrument flight procedure; or 2 NM from an airport without a published instrument flight procedure or operational tower; or 2 NM from a heliport with a published instrument flight procedure. 10. Any UA S’s operated by

Photo Elevations LLC would be properl y identified by serial number, registered in accordance with 14 CFR 47, and have (N

-Number) markings as large as practicable. 11. The UA must remain clear and give way to all manned aviation operations and
activities at all times. 12. The UAS may

not be operated b y the PIC from any moving device or vehicle.


### Proposed UAS’s For Exemption and Their Physical Descriptions Depending on our photographic, environmental safety and/or atmospheric conditional needs, we h ave three UAS’s prepared for business operations. At this time we formall y request exemption for the DJ I Phantom 3, DJI In spire 1 and DJ I Spreading Wings S1000+; all of which have had precedent rotorcraft UAS Section 333 exemption approval by the FAA. A s performance and safety technologies quickl y advance, we too should advance with them. Therefore we respectfully request the approval to update our DJ I series systems software and hardware when need be as long as they f it within the FAA’s UA size and weight parameters and follow all further imposed regulations.
These are the latest models in their class from DJI, a worldwide leader in technologicall y advanced small rotorcraft, radio controlled (RC) aircraft. E ach of the proposed models
are equipped with highly advanced control and navigational features and fit within the prior safety requirements set forth b y the FAA.

In cluded with this petition for exemption are the proposed model flight safety guidelines, battery s afety guidelines and maintenance manuals for the DJ I Inspire 1, Phantom Series and Spreading Wing S1000+ series. Due to the large size data files of the pilot trainingmanual and user manuals (exceeding the 10MB file maximum allowed for online

submissions) and prior precedent exemption grant s by the FAA for each proposed UAS, full user manuals (containing all specifications) are not included with this petition. They are available upon request or at the following website links: **DJI Inspire 1:** http://download.dji

innovations.com/downloads/in spire_1/en/Inspire_1_User_Manual_v1.0_en.pdf **DJI Spreading Wings S1000+** http://download.dji

innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf **DJI Phantom Series:** (Phantom 3 manual not yet available online) http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_ Manual_v1.8_en.pdf **DJI Pilot Training Manual:** http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_ Training_Guide_v1.1_en.pdf
**UAS R adio Frequencies**  All devices used will comply with the FCC usage and emissions regulations and guidelines. The radio frequencies used will also comply with the allotted FCC frequencies for data transmission and vehicle control in unlicensed frequency b ands. (More on radio frequencies provided on the specification/user manuals included with this petition.)


### About our Location Bemidji is located in North

- Central Minnesota. With a population of nearl y 15,000, Bemidji is a central hub of an expansive rural territory made up of agriculture farmlands and dy namic forests both privately and publicl y owned. Lakes, bogs and grasslands are also abundant. Amajority o f our aerial operations would take place in extremely remote, rural locations.



### Public Safety, Pri**vacy and Environmental Impact** Photo Elevations LLC is very excited to have our foot in on the ground floor of such an extraordinary

and electrifying new industry

. A s mentioned before, flight safety is of the highest importance and we vow to maintain all regulations and guidelines to the highest standards. These standards would also adhere towards all privacy rights and environmental impact issues.
This new sUAS technology virtually releases both the environmental and economic restraints on a level never fathomed before in the aerial photography industry

. Traditional methods of piloted aircraft for our proposed purposes are extremel yexpensive, produces high levels of toxic emissions into the atmosphere, carry large

payloads of flammable fuel and greatl y increase the risk of human endangerment. F or those reasons, Photo Elevations LLC b elieves its proposed services are in the best Public Interest. Our small, lightweight, micro UAS’s run on rechargeable LiPo batteries and produce zero toxic emissions during flight. They ’re highl y controllable with advanced safety features for stabilization, GPS navigations, electronic speed controllers, autopilot safety modes and real

-time data transmissions and recording. Overall, the proposed UAS’s greatl y increase publ ic safety and benefits as compared to conventional methods of aerial photography. 

### Pre and Post Flight Checklist/Inspections

To include, but not be limited to the following:
1. Inspect all parts and system components for proper working condition. In cluding, but not limited to:
a. Actuators/Servos b. All Motors
c. Wiring and Connectors d. Propellers, cleaned, inspected for damage, mounted correctly
e. Electronic Speed Controllers f. Batteries Levels and Condition of all power supplies. g. Remote Control Functions and Settings h. Ground Station equipment and connections
2. Conduct preflight safety discussions and assessments regarding areas of concern and taking steps to minimize all safety risks prior to flight. 3. Proper clearance of NAS, if need be, and proper permis sion for land use. 4. Spectator, Crew and Public Safety management. 5. Must have on hand all necessary flight documents, handbooks, exemptions, etc. 6. All preflight inspections and operational testing recommended in the UAS user and operational manuals.



### Condition **s** Photo Elevations LLC will only c onduct operational flights under ideal visual meteorological conditions (VMC). No flights will take place in obstructed view locations or during unpredictable weather conditions. No flights will be conducted less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. No flight operations will be conducted at night. All flights will be aborted in the event of unpredicted obstacles or emergenc ies.

### Licensing and Supporters of Photo Elevations LLC

Photo Elevations LLC has obtained proper State and Lo cal licensing, extensive liability insurance coverage, and proper Federal and State Tax Identification Numbers, as well as, approval support from local Law Enforcement, Bemidji Fire Dept., City C ouncil Members, Local Business Owners and the Chamber of Commerce. Acceptance of this emerging technology

i s growing fast through the use of the tremendous visual benefits. Seeing is believing and Photo Elevations LLC wants to help show our Community a new vision and the amazing reimbursements that flow with. 

### Petition Summery **Petition Pursuant:** Photo Elevations LLC Michael Finnegan, Owner/Operator 2508 Eagle Lane NE Bemidji, MN 56601 218

- 368

- 1375 photoelevations@yahoo.com **Re: Expedited Exemption Petition of Section 333 of the FAA Reform Act of 2012**
**Photo Elevations**  **LLC respectfully**  **requests exemption**  **from the**  **following Federal**  **Aviation Administration (FAA) regulations:**  14 CFR Part 21, Subpart H, 14 CFR Part 27, 14 CFR sections 45.23(b), 61.101(e)(4) and (5), 61.113(a), 61.23(a) and (c), 61.315(a), 91.103, 91.105, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), 91.7(a). **Proposed UAS’s: DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S1000+ Proposed Uses:**  Real Estate and Land Development Agricultural Commercial Photography Public Safety

Services Aerial Surveying Botanical and Wildlife Studies/Assessments Invasive Species Detection 

### Conclusion Photo Elevations LLC would like to thank you again for your time and consideration. The FAA has granted prior exemptions in circumstances similar in all material respects to those presented in this petition. W e strongl y believe our services will greatly b enefit the surrounding community

and serve in the public’s overall best interest as a whole. For the preceding reasons listed throughout this petition, Photo Elevations LLC formally asks for these exemptions. Thank you. Sincerel y, Michael Finnegan